prescribed form duly signed by the Accountant. As
per section 92D(3) in respect of any such person who has entered into
international transactions ... such
person to furnish any information or document as prescribed in section
92D(1) within a period of 30 days from the date of issue
notice U/s 92CA(1) r.w.s. 92D(3) of the IT. Act, 1961 "
3. "Whether on the facts ... particularly, Section 92 , 92C and section 92D of the I.T. Act
and Rule 10C, Rule 10B(1), Rule 10B(2) and (3) and Rule
furnish ''copies of information and documents
maintained u/s 92D(1) of I.T. Act read with rules 10D(1) & (3) alongwith ... obligation to furnish
all the relevant informations and documents maintained u/s 92D(1) of
it read with rules 10D(1) & (3) of Income
failure to keep information and documents u/s 92D of
the Act and also for failure to furnish the same. In response, the assessee
replied ... required by sub-section (1) or sub
section (2) of Section 92D of the I.T. Act, 1961 during the course of
assessment
been initiated for failure to furnish information or
documents under section 92D of Income-tax Act, 1961?".
2) The Appellant prays that the order ... assessee has not furnished the information
or documentation as required under section 92D(3) of the Act in respect of
the international transaction not reported
assessee had failed to maintain the
requisite documents as specified u/s 92D read with Rule 10D of
the IT Rules. Thereafter, a separate penalty ... levied for
non-maintaining documents as specified in section 92D r.w.r. 10D,
without discussing the case on merits".
8. The ground raised
maintain the necessary
documents prescribed under Rule 10D read with section 92D(3) of the
Income-tax Act.
3 The appellant prays for leave ... information
or document as required by sub-section (3) of section 92D . As a
matter of fact he has accepted the Transfer Pricing Report
assessee had not maintained the documents and
information as required u/s. 92D r.w.r. 10D of the I. T Rules, that value ... exceeding Rs.1 Crore, that as per rule 10D r.w.s.92D & 271AA,that assessee had
to maintain and keep prescribed information
passed penalty order u/s 271G
r.w.s. 92D of the Act on 18.10.2018 levying penalty ... furnish documents and information as required under the provisions of
section 92D(3) of the Act and failed to show any reasonable cause for such
requisite information and documents as sought by the
Ld. TPO under Section 92D of the Act read with Rule 10D(1) and Rule ... Rules, 1962 ('Rules') within the time limit
prescribed under Section 92D(3) of the Act;
2.2 That